#10. This section contains heresay. Rogers repeats what she believes someone else said and she does so selectively. I don't believe this should have been allowed. Repeating anything my father says, in particular, should not be admissible as he has dementia. Describing others as argumentative is something Rogers does when others do not acquiesce to her demands as though people are not allowed to express an opinion, as though people should just do what she says.

#11. Rogers decribes a clearly unused room. The door is closed. It is not accessible to the cats, so not part of the cat housing.

#12. Rogers writes, "I visualized at least three cats in this room laying on the desk and four more laying underneath plastic bags and trash on the floor." There may have been cats attempting to hide from the predators in their territory, and they do like plastic bags and containers, but I have never seen cats lying under the bags in this room. What Rogers calls trash, my father calls things he may need later.

She also writes, "Both cats were squinting with their left eyes and had discharge from their eyes." Rogers appears to have confused her left and right. The appearance of these cats is perfectly normal for them and no indication of any medical issue that requires treatment. You will see photos of both cats on this and our Facebook page taken while in the custody of the state and they look no different, often worse, after having treatments at the state-approved shelter. Also, one of the cats had just been to the veterinary and required no treatment for his eyes.

Rogers writes, "...room that was piled and cluttered with items leaving a walking space to the door..." I don't dispute the room is cluttered, but then she goes on to write, "Hairballs, cat food and cat litter lined the corners of the floor." That is a clear fantasy. The room is piled and cluttered with items, yet she can magically see the corners of the floor?

#13. Rogers writes, "Another room to the right was a bathroom with cat hair and litter around the floor. It contained a litter box with multiple piles of feces." Yes, the cats actually use the litter boxes. Shocking!

#14. Rogers describes the area in the photo as "Behind the recliner were more filled cardboard boxes, papers and a litter box with feces inside." Despite the clutter around them, as you will see, the litter boxes are kept pretty clean.

She writes, "Behind the woodstove were two small dishes containing dry cat food." There are actually three dishes, they are about three quarters full and they are not small. This is one of several feeding stations, proving the cats are provided with multiple and separate resources. Rogers refers to two kittens in this room, "Both kittens had obvious eye and nasal discharge." Which is why my father brought them inside so I could treat them. Two or three more days of treatment and their symptoms would be gone.

#15. Rogers writes, "A room adjacent to this contained a cart with a large cardboad Amazon box with at least seven Hannaford plastic bags of dirty cat litter." All litter boxes had been emptied late the day before. The used litter goes into bags and those get carted out to the barn for storage until they can be collected for composting. Carting these bags out through the barn at night is unpleasant and I was tired, so I left the cart and bags for the next morning. This proves that dirty litter is regularly removed from the housing area.

She describes, "An orange and white cat sat on top of the table that had hair missing from both ears, a squinting left eye, some sort of bandage/wrap around its neck and leg and obvious wounds to the left side of its neck and back." This is Major and he looks much better than the day he tore up his ears. His condition is described in another article that includes two other cats with a similar issue. He was receiving medical treatment at home. His ears are healed, just some more cleaning left to do. A couple of long scabs remain on his neck and there is a raw spot on his neck where he was able to scratch under the bandage. Note he does not have any eye or nasal discharges. His left eye improved as the ear infection cleared, but it doesn't look much different a year later when he returned home. He was due for a bandage change that morning, so his nonstick pad is slipping and his bandage is looking bedraggled. Timing is everything. This cat was allowed to scratch himself while in custody and eight days into care by the state was at the veterinary with large areas of scabs and oozing pus, thereby undoing all my hard work to keep him from injuring himself.

#16. Rogers writes, "A calico colored cat sat next to the woodstove and watched us walk through." Note this cat had no signs of any eye or nasal discharges. This, of course, is not commented upon by Rogers. This cat managed to escape capture by the state. And yes, there is a collection of cat hair on the floor.

Rogers writes that two kittens were playing in this room. These two were among the symptomatic outdoor kittens just brought into the house the day before for treatment. These kittens were obviously feeling well enough for normal play activity. It's important to note that though the kittens had obvious symptoms, they were all eating, drinking and playing. And most importantly, receiving medical treatment. But the state didn't ask if any of the cats were being treated.

#17. Rogers writes, "The large stove...caked with cat hair and cat litter." The stove is not "caked" with cat hair and cat litter. This is more exaggeration. The cats like to lie on the stove because the pilot lights make it a warm place, so it does get cat hair on it, but it doesn't have cat litter on it or caked on cat hair. Rogers continues to exaggerate when she writes, "The floor in this room was also covered in hair, trash, cat food cans and cat litter." The floor is not "covered" in anything or you wouldn't be able to walk around in it. The unfinished plywood floor has been unfinished for more than 30 years. It doesn't look clean even when it's clean.

One of the kittens brought into the house for treatment is referenced in this room.

#18. Rogers states, "...with a pile of cat feces on top." This is the only cat poo outside the litter box areas and within the cat living areas that had not yet been seen and cleaned up. She also states, "There were two litter boxes... The boxes were soiled, and litter was scattered around the boxes with a pile of feces on the floor." There are actually three litter boxes at the far end of the room, and yes, the cats actually use them and "soil" them and scratch litter onto the floor and some prefer to poo just outside the boxes. Again Rogers writes the floor is "covered" in hair, cat litter and dirt.

This state photo was taken after cats ran through in terror and displaced items in an attempt to flee the predators chasing them.

#19. This room contained a staircase, five windows and a windowed door. Lots of light, lots of air, lots of room for play. In this room, again Rogers finds, "The entire floor was covered in dirt, cat hair and cat litter." The cats did enjoy making a mess climbing and shredding the mountains of cardboard boxes.

These poor cats are still waiting for their morning feeding while I'm stuck out in the barn and the state goes about their dastardly business.

#20. These rooms are described as "filled and piled with items and almost inaccessible, not even a walking path had been left open." You can see that Rogers and another person were able to walk through the room. This is clearly an unused room. The door to this room was closed and the room had no cats in it.

The other room was also closed and unused by humans or cats, but the cats managed to wedge open a door to the room, knock stuff around and use the unfinished bathroom as a toilet. This was my mother's old room. I had not been in the room in over a year and was not aware the cats had gotten into it. This room was clearly not part of the cat housing, yet the state chose to admit multiple photos from this room into evidence.

#21. The description states, "...the entire floor contained cat litter and cat hair." This state photo clearly shows this to be untrue. This area is cleaned daily because as the photo shows, the cats often do their business beside the litter boxes instead of inside them. You would have to arrive soon after a cleaning to not see this situation and the floor always looks sandy in color until it gets a complete wash.

#22. This is the "bedroom type area" described by Rogers. It may be messy and cluttered, but it is clearly a bathroom. The mother cat described by her had just come inside to have kittens, chose a less than ideal place and didn't particularly want to accept my suggestions for her and kept leaving her kittens alone, but finally allowed that this box and this room were acceptable. It took me several hours to settle her down, so you can imagine how I felt about the state's interference. The door to this room was closed. She had plenty of food and water, a heater that was running as this was early November, a litter pan and privacy. She was started on medical treatment similar to treatments she has received from the veterinary in the past. She successfully raised a litter of four kittens two years ago, so the state's concerns about her ability to do so now are conjecture.

#23. This is my office. I keep the door closed to limit the number of cats in the room. Rogers writes, "Another room contained a recliner and other furniture around the room. There were kittens of various ages playing on and under the recliner as well as an adult cat that I could visualize." Sounds like it could be a room in anyone's house, doesn't it? The state took no photos of this room. There is always food and water available to the cats in here, including kitten chow, and it contained three kitten-sized litter boxes. My three kittens on bottles were kept safely isolated in here. Several adult cats who are especially bonded to me are allowed in and out of this room and were in here at the time of the seizure. A reasonable person would think animals engaged in normal play activity indicates they are happy and healthy.

#24. This room contained three windows, a king-sized bed, a dresser and a bookshelf. The bed mattress has a plastic protective cover plus a water resistant pad and the bed is made with a clean bedspread and covered pillows that the cats sleep on. Rogers describes this room as, "The floor and other items were soiled with cat feces, cat hair and dirt." Once again, Rogers puts feces on everything. You can see from the photos to the right and far right that there are no cat feces on any surfaces. The only poos were in the three litter boxes. These photos were taken by me after the state had removed the cats. The state didn't take any photos that included the clean bureau top. The state tossed the king-sized mattress and two box springs and left them that way. The bed frame was warped by this activity. They tossed the blankets and pillows onto the floor and left them there.

A shade was knocked onto the floor and a window had broken and fallen panes. This is evidence of cats slamming into the windows in an attempt to escape predators. Their large ceramic water bowl sits on the clean bureau top. A now broken keepsake sculpture that was on a shelf in a closet behind a closed door where there were no cats sits next to it. One of the sweet cats who was in this room was found dead in his cage seven months after his capture by the state. And the state never expressed a single ounce of sympathy for his loss.

#25. This space was also behind a closed door. It is attic space that the cats gained access to from an open ceiling on the first floor that we closed once, then reopened for fear of trapping cats in that space. Rogers writes, "However, another cat that had a bandage around its neck was caught and identified as C74." Even this is not accurate as I saw this cat captured downstairs when I had to come inside to use the bathroom. No photos were taken of this attic space. Because of this terror event, I not only leave the ceiling open, but now leave the attic door open so the cats can escape into their safe room when they feel treatened. Most of them now make a beeline for it when a stranger enters the house. I would prefer to close this space, but I don't know if we'll ever feel safe enough to do it.

#26. The cats are not allowed in the basement. However, the door was opened during the search and seizure and one cat ran down there to hide.

#27. The cats who hang out in the cow barn have plenty of food, water and shelter. The photo to the right is of Tiggy, one of the feral spayed cats in the barn. Unfortunately, she fell victim to whatever the state uses to lure cats into traps. She would hate being confined to a cage like she has been in the hands of the state.

#29. This description says, "During the course of the seizure the animals were provided water and let out of the coop to free roam." The state photos of the coop taken around 11:18AM prove they knew the birds were out of water at that time and did nothing about it. It wasn't until around noon that I finally insisted I be allowed to open the coop so the birds could find water. The birds did not, however, get water inside the coop until the state left because I get the water from the house and I was not allowed in the house except to use the bathroom.

#30. This describes a pile of used cat litter in the back of the barn. The barn is where it is normally stored until we get out the tractor and take it away for composting. There is nothing unusual about manure storage on a farm. There are no animals housed in this barn. It is far from the cat housing. All this does is prove that animal waste is removed from the animal housing.

This description also states that they were able to catch one of the barn kittens. These are feral kittens who cannot be caught until they are too sick for fight or flight. The state mistakenly identifies this kitten as fearful or social. It's very disturbing to me that this feral kitten, shown in the photo to the right, who had never been touched by a human before, was held in this careful manner while my cats who were used to being held carefully were all grabbed by the scruff of their necks or trapped in nets. They had never been mistreated in that way before. The sibling to this kitten was able to complete its medical treatment at home and continues to run free and healthy around the property having a grand old time while the fate of this captured kitten, who has not been returned, remains unknown.

Can you even imagine a stranger coming into your house uninvited, chasing, cornering and capturing your cat in a net or grabbing and picking it up by the scruff, sticking it in a cardboard box, stripping it of its name and history and trucking it off to some secret location?

#31. When Rogers was done and handed me paperwork, she said, "This is because you wouldn't let us in the house." And she said, "We know we didn't get all of the cats" in what I felt was a threatening manner. Then she said the house wasn't a healthy environment for the cats. My response was, "Seriously?" To which she replied, "I'm not going to argue with you." She has said this before when I didn't agree with her. I wonder if she realizes it really means, "I don't care what you have to say." It's pointless to speak to someone who just doesn't care, so naturally this works to stop people from speaking with her.

Rogers writes, "I stated they are all listed on the forms I had just handed her." And they are serious when they say these things. I was not consulted as to the identification of any animal, so this log is a poor identification instrument. It is improperly filled out and many fields are left blank. As will be shown, there are many errors in the description of the animals and between this log and the medical exams. This shows the state is not concerned about properly identifying individual animals.

Rogers writes, "Ms. O'Connell stated that she has no idea what cat is what and questioned if we identified them accurately." I certainly would never have stated I have no idea "what cat is what" since that's poor English, but also because I most certainly do know who is who. I did not question if they identified them accurately because they obviously could not have done so. I asked how I could possibly identify animals to surrender when I couldn't tell who was who based on their form.

Strout told me I should just sign over all the animals. I told him I wasn't going to sign their death warrants and he said, "That's not going to happen." During a phone conversation I had with Strout, I learned he doesn't even know how many animals are killed in shelters in this state.

During that same phone call, Strout mentioned hoarding and said to me, "You think the state can't get into your house if they want to?" Both prejudice and misuse of the law seems to be a common thread through animal welfare in this state.

Rogers asked me if I had any questions, so I asked if the kittens had been fed to which she replied, "They'll be well taken care of." This is a dismissive reply, not an answer. She didn't ask which kittens I meant, so she clearly didn't intend to provide a meaningful answer to the question, nor was she concerned that there might be starving kittens in her care. At that point the kittens, normally fed every three hours, hadn't been fed in over eight hours. As far as I'm concerned, that put their lives at risk and I am prevented from doing anything about it because men with guns are allowing it to happen. I took the papers and went back into the house as it was pointless to speak to Rogers. You will see from Rogers description in #23 that she found the kittens I'm referring to playing in my office. The state assigned the IDs 51/53/54 to these kittens. They received medical exams the next day and all three were described as very thin, the two youngest needed fluids and days later several were sent to Falls Road Veterinary for further treatment. Their condition clearly deteriorated in state custody, so they were not "well taken care of."

#32. Brief response to medical findings:
a. Body Weight
The state identifies 27 out of 82 as very thin. I contest body condition evaluations as given to bias. At least six cats had been recently evaluated by independent veterinarians and all received higher body condition scores than the state approved veterinarian gave them. Only four received body condition scores on triage on 11/5, but of those four, three received lower body condition scores the following day from the state approved veterinarian. In addition, Rogers' counts are incorrect. The correct numbers are 27 scored 2, 26 scored 3 (Rogers counts 31), seven scored 4, 13 scored 5 (Rogers counts 14), one scored 6, one scored 9, one was illegible (but Rogers gives it a score of 5), one had no exam record (but Rogers gives it a score of 3), one had no score and four were newborns (but Rogers gives them each a score of 3). Assigning a low score of 3 to an animal who was not scored and to newborn kittens who cannot be scored is consistent with the errors and bias seen throughout the state's documentation.

b. Eyes
The state identifies 72 out of 82 with medical eye findings. Per state exams, I identify eight with no findings, 14 with just crust in the corner of their eyes, 17 with a mild discharge, four with a clear discharge, one with no record and 38 with other findings. Of the 38 with other findings, photos of six show no or milder findings and eight have permanent eye damage from when they were kittens. Out of 82, 35 were prescribed eye medication. Two cats have conflicting diagnosis that would move them from other findings to no findings. Since most cats were caught in nets, it's quite possible that eye trauma occurred as a result of this capture activity. Falls Road did a fluorescein dye—used to identify corneal ulcers—on 12 cats and all were negative. In 20 of 42 cases where the eyes are visible in photos, the photo evidence indicates milder symptoms than the 11/6 findings. It is normal for cats to accumulate material in the corners of their eyes, just like it is for humans. Cats with truly notable eye issues were being treated at home, including seven kittens found outside and brought inside for treatment. See page on Feline Herpesvirus. Without knowing the cats or speaking to the owner, you cannot know at which stage is their infection or treatment.

c. Nose
The state identifies 69 out of 82 with medical nasal findings. Per state exams, I identify 20 with no findings, 16 with a mild discharge, 10 with a clear discharge, one with no record and 35 with other findings. The state indicates three cats had ulcers on the front of their noses—one was bloody—but these injuries were not present before the seizure and given the violence of the capture activity were most likely caused at that time. In 16 of 42 cases where the nose is visible in photos, the photo evidence indicates milder symptoms than the state approved veterinarian findings. It is normal for cats to sneeze and have a nasal discharge, just as it is for humans. Cats with notable nasal discharges were being treated at home, including seven kittens found outside and brought inside for treatment. See page on Feline Herpesvirus. Again, without knowing the cats or speaking to the owner, you cannot know at which stage is their infection or treatment.

d. Mouth
The state identifies 61 out of 82 with oral medical findings. Per state exams, I identify nine with no findings, 16 with no exams, 10 with just gingivitis and 47 with findings. The American Veterinary Dental Society reports that 70% of cats show signs of oral and dental disease by age three, so there is nothing unusual about these findings. My cats, however, have never shown on veterinary exam the degree of complaints the state approved veterinarian noted and with one exception, have never indicated a problem when eating. That one exception had a dental four years ago with no issues found. One cat was noted on 11/6/19 exam as needing urgent dental care, but wasn't seen by another veterinary until 11/13/19 and no dental work was done or recommended. Ten cats had dental extractions at Falls Road. The soonest occurred on 11/19/19, two weeks into state custody.

e. Ears
The state identifies 70 out of 82 with ear issues. Per state exams, I identify 13 with no ear findings, 22 with mild ear debris, 28 with moderate ear debris, one with no record and 18 with other findings. Cats naturally have ear debris. Six cats had been seen by two different independent veterinarians who did an ear cytology and found no live mites or eggs. All other reports of ear mites are opinions based on visual examination only. Ear infections are not always obvious and the ones that are can be notoriously difficult to resolve and that includes treatments prescribed by the veterinarian. I had a cat who lived half his life with an ear infection until our veterinarian found a new antibiotic that worked. I have identified a number of other treatments that work, but the same treatments don't work on every cat and positive results can be temporary. Of course the cats are treated for ear mites and ear infections.

f. Skin
The state identifies two out of 82 with bandages. These two cats, Major (C9) and Sargeant (C74), were healing, did not require immediate medical attention, were in no immediate danger, and are discussed in other articles.

e. Other Findings
My cats do not have fleas. I dealt with a flea outbreak nine years ago in a small population and the assumption there could be a flea outbreak in this large population that is completely invisible to me is unreasonable. Of the 15 cats the state veterinarian alleges have flea dirt and 38 cats claimed to have scabbing, only seven allegedly had both, so while the state tried to say the skin condition was an indication of fleas, there is no significant correlation between the skin scabbing and fleas. Other veterinarians who saw the cats found no fleas or flea dirt.

There were two cats with self-inflicted wounds. Any other wounds were created when the cats fled in terror from the human predators, most notably a bloody nose on Foxtrot (C12). My father witnessed a cat's tail being grabbed and pulled as the cat attempted to flee into a ceiling cubby. Also, possible cuts from window glass being broken as the cats attempted to escape.

Scabbing on body was a new issue and may have been caused by a change to a grain-free food. As of 9/11/20, we are back on less expensive varieties and there is none to very little scabbing.

Head tilting occurs in two cats who have been like that since they were kittens.

Dandruff is noted on the exams in exactly two cats.

Hair matting is described on two cats, one who doesn't like to be touched and one who is a feral barn cat. This was extremely minor matting, one or two small matts.

Since dehydration can occur in a matter of hours and the medicals were done on the day following the seizure, increased skin turgor is most likely caused by the state's activities and confinement in a new, frightening environment. Only one very sick feral barn kitten was noted on the day of seizure to be dehydrated. All cats have ready access to fresh, clean water in their home environment, both from bowls and fountains.

Heart murmurs were identified in two cats. Neither of these are the one cat who was known to have a heart murmur. One of the state diagnosed cats has been seen multiple times by independent veterinarians and there has never been a diagnosis of a heart murmur.

Open mouth breathing was described in one cat and can occur from being stressed or anxious.

Tremors occur in three cats and are not treatable or caused by lack of treatment, but were exacerbated by the state's actions.

Limb deformity occurs in two cats and are not treatable or caused by lack of treatment.

My cats do not have lice and this was proven by a tape test done at the Falls Road Veterinary Clinic.

#33. Rogers adds what is clearly boiler plate language. Not a single cat was in any physical or psychological danger. Kittens—even those with visible signs of illness—are described by Rogers as being engaged in normal, healthy play activity. The two cats who were taken to a veterinary clinic were clearly healing. Proper shelter, protection from the weather and sustenance availability are all obviously provided. Plus we know the state isn't actually seeking permanent possession of the animals. If they get the animals they will immediately gas many of them and give the others away to shelters who will sell them or eventually kill them as unadoptable.

Only half of the state photos show a clear view of the face, but almost half of those show no symptoms of illness. Those with visible symptoms were treatable at home. There is no evidence to support that the environment negatively impacted the welfare of the cats. Clutter does in fact contribute to an enriching environment as explained in another article. Feeding, watering, toileting and sleeping areas for the cats are clean. The only room with piles of excrement was clearly unused by the humans and thought to be closed to the cats.

I hope the bias in the way the state presents evidence is overwhelmingly clear. Even the 11 cats who had just been to the veterinary cannot be distinguished from the rest based on the state's presentation. The way the state lists ailments, stating that "70 out of 82 presented with..." is misleading, making it appear as though all 70 animals had all of those issues. The same with other findings presented as a list of issues as though many cats had those issues when it was only one or two. In this particular population of 124 cats, this certainly cannot be considered unreasonable, abnormal or unacceptable.